National
Assembly for Wales
Children, Young People and Education Committee
QW 03Qualifications
Wales BillEvidence
from: ASCL

1The Association of School and
College Leaders (ASCL) represents over 18,000 heads, principals,
deputies, vice-principals, assistant heads, business managers and
other senior staff of maintained and independent schools and
colleges throughout the UK. ASCL Cymru represents school
leaders in more than 90 per cent of the secondary schools in
Wales.

2ASCL Cymru welcomes the intention to
establish Qualifications Wales and the transfer of responsibility
for regulation and quality assurance of qualifications awarded in
Wales from the Welsh Government to this new body.

3We also welcome the decision to
establish this body as a regulator of qualifications in the first
instance and not as both regulator and awarder of
qualifications.

4It isn’t clear how joining the
functions of regulation and awarding in a single body would benefit
learners, teachers and other stakeholders nor lead to greater
public confidence in a Welsh qualifications system.

5Early discussions with Philip
Blaker, Chief Executive of Qualifications Wales, about how the new
organisation may approach outstanding concerns have been
encouraging.

6It is regrettable that the proposal
to establish this body was made in November 2012 but that this body
will only be established for September 2015. New
made-in-Wales GCSEs and A/AS levels and a revised and more rigorous
Welsh Baccalaureate have been developed over this period.
These new qualifications will be taught in classrooms from
September 2015 without having had the oversight of a properly
constituted and well-run independent regulator.

7It is unclear how the independence
of this new body will be maintained under the arrangements
described in the Bill. Welsh Ministers have the power of
appointment, the power of authoring remit letters and the power to
identify those priority qualifications that require a
pre-determined response by the regulator. Moreover, what
happens when the new body presents its Annual Report to the
National Assembly, and what if the report is found
wanting?

8It is fair that proper arrangements
are made for those civil servants currently delivering the
functions of regulation in the transfer of these functions to the
new body. However, the recent history of qualification
regulation in Wales does not inspire the confidence that there is
sufficient expertise and/or capacity among the current personnel to
deliver the robust and high-quality service that should be
expected.

9Qualifications Wales will inherit a
monopoly arrangement where the WJEC is the single provider of
high-status, high-volume and therefore high-risk qualifications,
including new GCSE English and GCSEs in Mathematics. It will
need to be effective and vigilant from the very first day of its
existence.

10Qualifications Wales will need to reassure
stakeholders that there are robust measures in place to ensure that
monopoly provider arrangements continue to deliver innovation,
responsiveness and a reliable service.

11The Bill allows for Ministers together with
Qualifications Wales to produce a list of ‘priority
qualifications’ and within these a further
category of ‘restricted
qualifications’.
Qualifications Wales will be able to restrict the number of forms
of a restricted qualifications to as few as one. This will only
apply to maintained schools. An example is given in
explanatory notes: “To take GCSE English for example, this
means that a pupil in a maintained school would only be able to
take the single Qualifications Wales approved version”.
Given the troubled history of awarding GCSE English in Wales, it is
essential that there is transparency about what is in place to
ensure the safety of the awarding.

12It is clear that there is an expectation that
Qualifications Wales will encourage more and not less monopoly
arrangements in certain key areas of provision that are deemed
strategically important by Welsh Ministers. Along with the
dangers that are inherent in all monopoly arrangements, it makes
the qualification system vulnerable to political
turbulence.

13Qualifications Wales will be tasked with
‘promoting public confidence in qualifications and in the
Welsh qualifications system’. This is very
welcome. It remains to be seen how this might be measured,
but the aim must be to secure a public perception that
made-in-Wales qualifications are valid, reliable and comparable
with other well-regarded qualifications available elsewhere in the
UK and beyond.

14Qualifications Wales will engage in
research. One of the pressures that affect qualifications and
how they perform in a school-setting is their use as a measure in
school accountability. It would be worthwhile looking at how
that pressure can be managed.

15Over time, it should be hoped that
Qualifications Wales establishes itself as an authoritative source
of independent analysis and commentary on the performance of
qualifications and assessment in our system. This might be an
opportunity to resolve the standards dilemma: when more of our
young people pass the exam, is it because they are getting better
teaching or are they cleverer than their predecessors or is it
because the exam is getting easier?